Popular meaning controls tax exemptions; ripened coconut was not treated as an exempt fresh fruit or vegetable.

Exemption entries in taxing statutes are construed in their popular or commercial sense, not by scientific or botanical classification, unless the statute defines the term otherwise. Applying that test, ripened coconut was not treated as a "fresh fruit" or "vegetable" for the exemption notification under the Tamil Nadu General Sales Tax Act, and the assessee failed to show that it was understood as an exempt article in the relevant market or locality. The claim to exemption therefore failed, and sales turnover from coconut remained liable to sales tax.

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Issues: Whether ripened coconut with or without husk is a "fresh fruit" or a "vegetable" within the exemption notification issued under the Tamil Nadu General Sales Tax Act, 1959, so as to escape sales tax.

Analysis: In interpreting items in revenue statutes, the terms must be understood in their popular or commercial sense and not in their scientific or botanical sense, unless the enactment defines them otherwise. Applying that test, ripened coconut is not what an ordinary householder would ask for as a "fresh fruit" or a "vegetable" for the evening meal. The fact that coconut may botanically be a fruit, or may be sold in a vegetable market, is not decisive. The assessee, who claimed exemption, also failed to adduce evidence showing that ripened coconut was treated as an exempt article in the relevant market or locality.

Conclusion: Ripened coconut is not exempt as a "fresh fruit" or a "vegetable" under the notification, and its sales turnover is liable to sales tax.

Final Conclusion: The exemption claim failed, and the assessment of coconut sales to tax was upheld.

Ratio Decidendi: Exemption entries in taxing statutes are construed in their popular or commercial sense, and the assessee claiming exemption must establish that the goods fall within the exempted category.

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